Summary Judgement Affirmed – Race Discrimination – Philadelphia Emily Mahler & Catherine Straggas
A manager employed by the Philadelphia Housing Authority for over 12 years alleged she was discharged from employment due to her race and national origin. Plaintiff sought damages totaling $300,000 for lost wages, compensatory damages and punitive damages. In June 2014, following oral argument presented by Emily Mahler, the District Court granted our client’s Motion for Summary Judgment, concluding the plaintiff failed to establish a prima facie case of race discrimination where the evidence adduced did not establish a discriminatory motive. In April, 2015, the U.S. Court of Appeals for the Third Circuit affirmed the lower court ruling rejecting the Plaintiff’s attempt to establish a prima facie case through alleged evidence that the asserted reasons for discharge were pretextual, noting that accepting such evidence as establishing a prima facie case would “upend McDonnell Douglas’ burden-shifting framework.” The Court further held that even assuming plaintiff could establish that the proffered reasons for discharge were pretextual, further evidence of racial bias was necessary to establish that the real reason for discharge was discriminatory.